ML17325B187
| ML17325B187 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/31/1989 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1090, NUDOCS 8904050258 | |
| Download: ML17325B187 (7) | |
Text
Dlc'TMBUTION DEMON ~TRAT10. i Fr's TEM AC CELE~T~
'I t
i3 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT:
Responds to NRC 890228 ltr re violations noted in Insp Rept 50-315/89-02
& 50-316/89-02.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR ENCL g SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response I
NOTES SSION NBR:8904050258 DOC.DATE: 89/03/31 NOTARIZED: NO DOCKET CIL:50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION DAVIS,A.B.
Document Control Branch (Document Control Desk)
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RGN3 FILE 01 RNAL: LPDR NSIC COPIES LTTR ENCL 1
1 1
1 1
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1 1
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1 RECIPIENT ID CODE/NAME STANG,J AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 O~EIEBE J
EG FILE 0
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I NOTE 'IO ALL "RIDS" RECIPZEZIS'IZASE HELP US K) REDUCE~!
CGNI'ACT '%HE DOCUMENT COBOL DESK, ROON Pl-37 (EXT. 20079)
KO ELIMINATE YOUR NAME FBCH DISXV~VI'ION LISTS FOR DOCUMENIS YOU DGH'T NEEDt TOTAL NUMBER OF COPIES REQUIRED:
LTTR 23 ENCL 23
Indiana Michigan Power Company P.O. Box 16631 Coiumbus, OH 43216 INOllllM NICHIGAN PDWM AEP:NRC:1090 Donald C.
Cook Nuclear Plant Unit No.
2 Docket No.
50-'316 License No.
DPR-74 INSPECTION REPORTS 50-315/89002 (DRP)
AND 50-316/89002 (DRP);
RESPONSE
TO VIOLATION U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Attn: A. B. Davis March '31, 1989
Dear Mr. Davis:
This letter is in response to W. L. Axelson's letter dated February 28, 1989, which forwarded the report on the routine safety inspection conducted by members of your staff.
This inspection was conducted from December 28, 1988 through February 7,
1989 on activities at Donald C.
Cook Nuclear Plant Units 1 and 2.
The Notice of Violation attached to Mr. Axelson's letter identified one violation associated with the "CD" emergency diesel generator at Cook Nuclear Plant Unit 2.
This violation is addressed in the attachment to this letter.
This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M. P. Al xich Vice President ldp Attachment cc:
D.
H. Williams, Jr.
W.
G. Smith, Jr.
- Bridgman R.
C. Callen G. Charnoff NRC Resident Inspector
-Bridgman G.
Bruchmann P04A50~~
'<0331 PDI>>
ADGCK 05000316 Ql PDC
ATTACHMENT TO AEP:NRC:1090
RESPONSE
TO VIOLATION
Attachment to AEP:NRC:1090 Page 1'RC Violation "Unit 2 Technical Specification 6.8.1.a requires written procedures be implemented as recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, which includes (at Section I.5) general procedures for the control of maintenance, replacement and modification work.,
Licensee Procedure PMI-2290 "Job Orders" is the general procedure for administering such work, and it prohibits declaring a safety related system or component operable with unapproved parts or materials installed (Section 3.7.1) and restricts work performed by Job Order to the scope of work indicated on the Job Order form (Section 3'.3).
"Contrary to the above, the Unit 2 "CD" emergency diesel generator was declared operable on December 29, 1988, following maintenance under Job Orders No
~
018459 (main bearing replacement) and No.
020974 (18-month. inspection) with unapproved material (gasket stock) installed, in lieu of a rubber grommet, on ops fuel line penetration through the fulcrum box.
Fabrication and installation of the replacement grommet were not within the scope of work indicated on either Job Order form."
Response
to Violation During the course of a scheduled 18-month inspection of the Unit 2 "CD" emergency diesel generator, a rubber grommet installed in a fuel line to the diesel was found to be in a degraded condition due to normal wear.
In accordance with the applicable maintenance procedure, a job order for replacement of the grommet was initiated.
The degraded grommet was then replaced with unapproved material installed temporarily to protect the fuel line while a combined operations and maintenance run of the diesel was conducted.
Upon completion of the combined run, the diesel was declared operable.
(1)
Corrective Actions Taken and Results Achieved All maintenance supervisors were reinstructed that any changes made to equipment as a result of maintenance activities must be approved prior to declaring equipment operable.
Written approval of alternate material for the case cited in the NRC Notice of Violation was provided on December 30, 1988.
The grommet was replaced with the approved material on January 20, 1989 under Job Order No.
39685.
(2)
Corrective Action Taken to Avoid Further Violation The actions taken in (1) above are designed to increase. the awareness of maintenance personnel to the necessity for strict compliance with maintenance procedures concerning
Attachment to AEP:NRC:1090 Page 2
parts replacement.
We believe that our strong procedural prohibition against unauthorized parts substitution coupled with this additional training will be effective in minimizing the incidence of this type of violation.
(3)
Date When Full Com lienee Will Be Achieved Full compliance was achieved on December 30, 1988 when approval for use of alternate grommet material in the fuel line was received from the AEPSC Nuclear Engineering Department.